3vs.JOHN W. HICKENLOOPER, Governor of the State of Colorado,Defendant.

COMPLAINT

FOR

DECLARATORY

AND

INJUNCTIVE

RELIEF

Peace officers and peaceable citizens join together to bring this action indefense of public safety, the Second and Fourteenth Amendments of theConstitution of the United States, and the Americans with Disabilities Act.Plaintiffs are 54 Colorado elected sheriffs, retired law enforcement officers, disabledindividuals, civil rights and disability rights organizations, licensed firearmsdealers, associations of law-abiding gun owners, hunting outfitters, and thefirearms industry, and a manufacturer of firearm accessories.

House Bill 13-1224 (“HB 1224”) bans outright all ammunitionmagazines sold or acquired after July 1, 2013 that hold more than 15 rounds of ammunition. HB 1224 also bans most other magazines of any size because itprohibits smaller magazines that are “designed to be readily converted” to holdmore than 15 rounds of ammunition.